ACA Mini-Series, Episode 2 Revised Version: Appointment and Job Changes Jan 2016
Agenda 1. ACA Employer Shared Responsibility 2. Review 3. Appointment Changes (Revised) 4. Periods Without Hours 2
Affordable Care Act of 2010 Employer Shared Responsibility Under the ACA UC is required to offer medical insurance to substantially all full-time employees Full-Time under the ACA means working 30 or more average weekly hours of service Medical Insurance offered needs to meet the ACA definition of Minimum Essential Value Core Meets this requirement 3
Affordable Care Act of 2010 Employer Shared Responsibility Failure to comply: PENALTIES!! The A Penalty If UC fails to offer medical coverage to the required percentage of full-time employees, and even one full-time employee who was not offered coverage enrolls in a plan on the ACA Marketplace and receives a premium tax credit or cost-sharing reduction from the government; the annual penalty to UC would be $2,000 times the total number of full-time employees in the UC workforce = $220 Million Systemwide The B Penalty If UC offers coverage that is neither affordable nor provides minimum value; the penalty is based on the number of employees who actually enroll in a plan on the ACA Marketplace and receive a premium tax credit or cost-sharing reduction from the government 4
Review 5
What s Changing and Not Changing?
AFFORDABLE CARE ACT New Guidelines for Initial and Continuing Benefits Eligibility
2016 Faculty & Staff Benefits Program: What s Changing? Definition of Average Weekly Hours changes/expands Continuing Eligibility: Hours Included in the Calculation 2015 2016 Average Regular Paid Time Average Weekly Hours of Service PAID TIME Any and All paid time, for example: regular pay, summer salary pay, paid time for vacation, paid holiday, paid illness, paid jury duty, paid military duty, or paid leave of absence, paid sabbatical, etc. SPECIAL UNPAID TIME Unpaid FMLA Unpaid USERRA Unpaid Jury Duty Unpaid Hours during special employment breaks of at least 4 weeks (501 hours max) 8
Initial and Continuing Eligibility
Initial and Continuing Eligibility Applies to Groups A & B If eligibility is awarded on Date of Hire, eligibility continues through Dec 31 st of the year following the first complete Standard Measurement Period. We are calling this the Beginning Benefits Eligibility period. Nov 2014 Dec 2014 Jan 2015 Feb 2015 March 2015 April 2015 May 2015 June 2015 July 2015 Aug 2015 Sept 2015 Oct 2015 Nov 2015 Dec 2015 Jan 2016 Feb 2016 March 2016 April 2016 May 2016 June 2016 July 2016 Aug 2016 Sept 2016 Oct 2016 Nov 2016 Dec 2016 Jan 2017 Feb 2017 Mar 2017 April 2017 May 2017 June 2017 July 2017 Aug 2017 Sept 2017 Oct 2017 Nov 2017 Dec 2017 DOH SRA III 4/1/2015, 50% indef. Beginning Benefits Eligibility 2017 Stability Period Standard Measurement Period Standard Measurement Period Standard Measurement Period Not able to measure until employed for entire standard measurement period Measure here. If 17.5 hours or above, benefits continue for 2017 stability period. If not, benefits end 12/31/2016 Admin Period Measure here. If 17.5 hours or above, benefits continue for 2018 stability period. If not, benefits end 12/31/2017 Admin Period Example of Appointment Type - Group A
ACA for UC Continuing Eligibility Groups A & B Based on a Look-Back at the average weekly hours of service after completion of a full Standard Measurement Period Standard Measurement Periods o Monthly Paid: November 1 - October 31 o Bi-Weekly Paid: Nov 9 Nov 7 odates for bi-weeklies will change slightly each year based on payroll deadlines 11 11
ACA for UC Continuing Eligibility - Groups A &B Standard Measurement Period o If average weekly hours are AT/ABOVE the threshold for benefits eligibility: o If not already eligible system will update to BELI 4 and a PIE for benefits is offered for an effective date of Jan 1 st of the next year o If already eligible benefits continue o If average weekly hours are BELOW the threshold for benefits eligibility: o If not already eligible continue to be not eligible o If already eligible loss of ongoing eligibility we will change to BELI 5 effective Jan 1 and initiate COBRA 12
Not Eligible on Date of Hire
ACA for UC Not Eligible on Date of Hire Groups A & B Initial Measurement Period o 12-month period starting with date of hire o Applies to all employees not initially eligible for benefits: BELI 5 o Group A: Initial Appointment less than 43.75% o Group B: Initial Appointment less than 75%/3 months o After 12 months - if average weekly hours are at/above the threshold for benefits eligibility during the Initial Administrative review, a PIE for benefits is offered o Group A: Average weekly hours of 17.5 or greater o Group B: Average weekly hours of 30 or greater o If not eligible, the next measurement for eligibility will follow immediately after the Standard Measurement Period 15
Not Eligible on Date of Hire Applies to Groups A & B Employees with appointments that do no meet the Initial Eligibility requirements will be assigned a BELI 5 and will be measured for eligibility 1 year after their date of hire, this is their Initial Measurement Period. If they continue to be not eligible they will be measured again at the end of the first full standard Measurement Period. Nov 2014 Dec 2014 Jan 2015 Feb 2015 March 2015 April 2015 May 2015 June 2015 July 2015 Aug 2015 Sept 2015 Oct 2015 Nov 2015 Dec 2015 Jan 2016 Feb 2016 March 2016 April 2016 May 2016 June 2016 July 2016 Aug 2016 Sept 2016 Oct 2016 Nov 2016 Dec 2016 Jan 2017 Feb 2017 Mar 2017 April 2017 May 2017 June 2017 July 2017 Aug 2017 Sept 2017 Oct 2017 Nov 2017 Dec 2017 DOH 4/1/2015, 25% Sr. Analyst Initial Measurement Period Initial Stability Period Standard Measurement Period Standard Measurement Period Standard Measurement Period Not able to measure until employed for entire Standard Measurement Period Initial Admin Period: Measure here. If 17.5+ hours, find eligible and offer benefits for initial stability period. If not, no eligibility If eligibility was not achieved at the end of the IMP, Measure here. If 17.5+ hours, find eligible and offer benefits for 2017 stability period. If not, no eligibility status continues thru end of initial stability Example of Group A - Not Eligible on the Date of Hire 25
Applying your knowledge 16
Scenario #1: Analyst IV, hired July 1, 2014; 100% time indefinitely; measurement results in 40 average weekly hours of service July 2014 Aug 2014 Sept 2014 Oct 2014 Nov 2014 Dec 2014 Jan 2015 Feb 2015 Mar 2015 April 2015 May 2015 June 2015 July 2015 Aug 2015 Sept 2015 Oct 2015 Nov 2015 Dec 2015 Jan 2016 Feb 2016 Mar 2016 April 2016 May 2016 June 2016 July 2016 Aug 2016 Sept 2016 Oct 2016 Nov 2016 Dec 2016 Jan 2017 Feb 2017 Mar 2017 April 2017 May 2017 June 2017 July 2017 Aug 2017 DOH 7/1/2014, 100% indef Analyst IV 10/31/15, Standard Measurement Period results: 40 average weekly hours. 17
Scenario #1 Answers Remains eligible for calendar year 2016 July 2014 Aug 2014 Sept 2014 Oct 2014 Nov 2014 Dec 2014 Jan 2015 Feb 2015 Mar 2015 April 2015 May 2015 June 2015 July 2015 Aug 2015 Sept 2015 Oct 2015 Nov 2015 Dec 2015 Jan 2016 Feb 2016 Mar 2016 April 2016 May 2016 June 2016 July 2016 Aug 2016 Sept 2016 Oct 2016 Nov 2016 Dec 2016 Jan 2017 Feb 2017 Mar 2017 April 2017 May 2017 June 2017 July 2017 Aug 2017 Beginning Benefits Eligibility DOH 7/1/2014, 100% indef Analyst IV Standard Measurement Period Standard Measurement Period Standard Measurement Period 10/31/15 SMP results: 40 average weekly hours. 2016 Stability Period 17.5 7/1/2014 12/31/2015 11/1/2014 10/31/2015 Eligible through 12/31/2016 18
Job Changes
ACA for UC Job Changes - Groups A &B Change in BELI resulting in greater benefits eligibility level provides the employee with a new Benefits Beginning Eligibility Period (BBE) 20
Limited to Career Appointment, Group A Jul 1, 2015: Appointed to Limited position, 45% indefinitely. Assign BELI 4 starting July 1, 2015; new PIE for Core benefits; this starts the Beginning Benefits Eligibility Period (BBE) Mar 1, 2016: The appointment is extended to 100%. Assign BELI 1 effective Mar 1, 2016; new PIE for full benefits; new Beginning Benefits Eligibility Period (BBE) Nov/Dec 2017: Measured for 2018 eligibility; avg. hours are above 17.5; Benefits continue for entire 2018 calendar year (as long as employed) Nov 2014 Dec 2014 Jan 2015 Feb 2015 March 2015 April 2015 May 2015 June 2015 July 2015 Aug 2015 Sept 2015 Oct 2015 Nov 2015 Dec 2015 Jan 2016 Feb 2016 March 2016 April 2016 May 2016 June 2016 July 2016 Aug 2016 Sept 2016 Oct 2016 Nov 2016 Dec 2016 Jan 2017 Feb 2017 Mar 2017 April 2017 May 2017 June 2017 July 2017 Aug 2017 Sept 2017 Oct 2017 Nov 2017 Dec 2017 Standard Measurement Period Standard Measurement Period Standard Measurement Period DOH 7/1/2015, 45% Assign CORE BENEFITS Not able to measure until employed for entire Standard Measurement Period Beginning Benefits Eligibility New Beginning Benefits Eligibility Appt increases to 100% on Mar 1, 2016, no break in service CHANGE TO BELI 1, NEW PIE Not able to measure until employed for another Full Standard Measurement Period Measure here. If 17.5 hours or above, benefits continue for 2018 stability period. If not, benefits end 12/31/2017 NOTE: Change in BELI resulting in greater benefits eligibility level provides the employee with a new Benefits Beginning Eligibility 15 Period (BBE)
Limited Appointment Reaches 1,000 Hours Group A July 1, 2015: Appointed to Limited position, 100% for 8 months. Assign BELI 3 starting July 1, 2015 new PIE for Mid-level benefits; this starts the Beginning Benefits Eligibility Period (BBE) Dec 2015: Reaches 1,000 hours so appointment changed to BELI 1 effective Jan 1, 2016; new PIE for full benefits; new Beginning Benefits Eligibility Period (BBE) Nov/Dec 2017: Measured for 2018 eligibility; avg. hours are above 17.5; Benefits continue for entire 2018 calendar year (as long as employed) Nov 2014 Dec 2014 Jan 2015 Feb 2015 March 2015 April 2015 May 2015 June 2015 July 2015 Aug 2015 Sept 2015 Oct 2015 Nov 2015 Dec 2015 Jan 2016 Feb 2016 March 2016 April 2016 May 2016 June 2016 July 2016 Aug 2016 Sept 2016 Oct 2016 Nov 2016 Dec 2016 Jan 2017 Feb 2017 Mar 2017 April 2017 May 2017 June 2017 July 2017 Aug 2017 Sept 2017 Oct 2017 Nov 2017 Dec 2017 Standard Measurement Period Standard Measurement Period Standard Measurement Period DOH 7/1/2015, 100% time for 8 months Assign BELI 3 Beginning Benefits Eligibility New Beginning Benefits Eligibility Not able to measure until employed for entire Standard Measurement Period Reaches 1,000 hours in Dec 2015; system automatically triggers a BELI 1 effective Jan 1, 2016 Not able to measure until employed for another Full Standard Measurement Period Measure here. If 17.5 hours or above, benefits continue for 2018 stability period. If not, benefits end 12/31/2017 Note: 1,000 hour rule still applies 25
100% Career Appointment reduced to 20% Group A July 1, 2015: Appointed to Career position, 100% indefinitely. Assign BELI 1 starting July 1, 2015; new PIE for Full benefits; this starts the Beginning Benefits Eligibility Period (BBE) January 1, 2016: Appointment reduced to 20%. Beginning Benefits Eligibility period continues until the first full Standard Measurement period has been completed Nov/Dec 2016: Measured for 2017 eligibility; avg. hours are below 17.5; benefits end 12/31/2016 Nov 2014 Dec 2014 Jan 2015 Feb 2015 March 2015 April 2015 May 2015 June 2015 July 2015 Aug 2015 Sept 2015 Oct 2015 Nov 2015 Dec 2015 Jan 2016 Feb 2016 March 2016 April 2016 May 2016 June 2016 July 2016 Aug 2016 Sept 2016 Oct 2016 Nov 2016 Dec 2016 Jan 2017 Feb 2017 Mar 2017 April 2017 May 2017 June 2017 July 2017 Aug 2017 Sept 2017 Oct 2017 Nov 2017 Dec 2017 Standard Measurement Period Standard Measurement Period Standard Measurement Period DOH 7/1/2015, 100% time Indefinitely Assign BELI 1 Beginning Benefits Eligibility 2017 Benefits Stability Not able to measure until employed for entire Standard Measurement Period Appt. reduced to 20% on Jan 1, 2016 Measure here. If 17.5 hours or above, benefits continue for 2017 stability period. If not, benefits end 12/31/2016 Note: Reduction in percentage DOES NOT result in loss of eligibility until hours are below the threshold following a Standard Measurement Period (SMP) 26
Appointment Change from Group B to Group A Feb 1, 2016: Appointed 90% per diem; assigned a BELI 4 upon date of hire April 1, 2016: Offered a 100% career appointment. Change to BELI 1; new PIE for Full Benefits; new Beginning Benefits Eligibility Period. Measurement threshold changes to 17.5 hours. Nov/Dec 2017: Measured for 2018 eligibility; avg. hours are above 17.5; Benefits continue for entire 2018 calendar year (as long as employed) Nov 2014 Dec 2014 Jan 2015 Feb 2015 March 2015 April 2015 May 2015 June 2015 July 2015 Aug 2015 Sept 2015 Oct 2015 Nov 2015 Dec 2015 Example #4: Appointment Change from Group B to Group A DOH Feb 1, 2016, 90% Per Diem, BELI 4 Jan 2016 Feb 2016 March 2016 April 2016 May 2016 June 2016 July 2016 Aug 2016 Sept 2016 Oct 2016 Nov 2016 Dec 2016 Jan 2017 Feb 2017 Mar 2017 April 2017 May 2017 June 2017 July 2017 Beginning Benefits Eligibility Aug 2017 Sept 2017 New Beginning Benefits Eligibility Oct 2017 Nov 2017 Dec 2017 Standard Measurement Period Standard Measurement Period Standard Measurement Period April 1, 2016 Offered a Career Position 100%. Change to BELI 1, PIE for full benefits Not able to measure until employed for entire Full Standard Measurement Period Measure here. If 17.5 hours or above, benefits continue for 2018 stability period. If not, benefits end 12/31/2017 Note: The average hours threshold used (17.5 hours or 30 hours) is based on the type of appointment (Group A or Group B) held on the last day of the measurement period 24
Periods Without Hours
Affordable Care Act of 2010 Average Hours Calculation of Average Hours must include: Special Unpaid Leaves = unpaid FMLA, unpaid USERRA, unpaid jury duty Employment Breaks = a period of at least four consecutive weeks but less than 26 weeks during a measurement period during which an employee of an educational organization does not work 26
Per Diem, Biweekly Paid with Periods of 0 Hours Jan 1, 2013: Appointed 90% Per Diem, scheduled 36 hours/week Nov/Dec 2015: First standard measurement period ends; hours average 36 Jan 1, 2016: BELI changed to 4; new PIE for CORE benefits April 2016: Schedule drops to 12 hour/week and employee works 0 hours for two 8-week periods but is not separated Nov/Dec 2016: Following the next Standard Measurement Period UC must review the special employment break if the break is 4 weeks or greater but less than 26 weeks, UC must credit hours in each week up to a maximum of 501 hours during a measurement period Nov 2014 Dec 2014 Jan 2015 Feb 2015 March 2015 April 2015 May 2015 June 2015 July 2015 Aug 2015 Sept 2015 Oct 2015 Nov 2015 Dec 2015 Jan 2016 Feb 2016 March 2016 April 2016 May 2016 June 2016 July 2016 Aug 2016 Sept 2016 Oct 2016 Nov 2016 Dec 2016 Jan 2017 Feb 2017 Mar 2017 April 2017 May 2017 June 2017 July 2017 Aug 2017 Standard Measurement Period Standard Measurement Period Standard Measurement Period Sept 2017 Oct 2017 Nov 2017 S M P Dec 2017 DOH Jan 1, 2013, 90% Appt, Per Diem Measure here. Hours Avg 36. Jan 1, 2016 BELI changes to 4 and Core Benefits Offered New PIE 2 month period of no hours in February/March and July/August but not separated; Must credit hours and recalculate the average weekly hours 2016 Stability Period Measure here. If Avg Wkly Hrs of Svc are 30 or more benefits will continue. If less than 30 hours, change to BELI 5. 2017 Stability Period 38
Affordable Care Act of 2010 Employment Breaks If employees are not expected to work, departments should consider the impact of allowing them to remain inactive vs. separating them Employees who are not separated will accrue employment break credits Separation will stop the need to calculate employment breaks 28
ACA for UC New Beginnings Jan 2016 and forward Effective January 1, 2016, employees will not be enrolled in default coverage(s) if they do not take action No more default to Core medical, dental or vision Only default is Core Life Insurance Assigning a BELI at the time of hire will be based on new and current eligibility for all employees Benefits-eligible employees will be allowed to maintain coverage for the entire year. No more flip flopping! Group Insurance Regulations will need to be updated to reflect new eligibility rules 29
QUESTIONS????? EPISODE 3 Coming Soon: UC s 2016 Benefits Eligibility Rules: and Leaves of Absence